Steven Matthew Langley - Page 1

                                         T.C. Memo. 1996-164                                              

                                      UNITED STATES TAX COURT                                             

                             STEVEN MATTHEW LANGLEY, Petitioner v.                                        
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                     

                  Docket No. 27042-95.                    Filed April 1, 1996.                            

                  Steven Matthew Langley, pro se.                                                         
                  Lynne Camillo and Lynda B. Taylor, for respondent.                                      

                                         MEMORANDUM OPINION                                               

                  DAWSON, Judge:  This case was assigned to Special Trial                                 
            Judge Robert N. Armen, Jr., pursuant to the provisions of section                             
            7443A(b)(4) and Rules 180, 181, and 183.1  The Court agrees with                              

            1 Unless otherwise indicated, all section references are to                                   
            the Internal Revenue Code in effect for the taxable years in                                  
            issue, and all Rule references are to the Tax Court Rules of                                  
            Practice and Procedure.                                                                       

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